jjwan Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how jjwan ("jjwan", "we", "us" or "our") collects, uses, stores, shares and protects personal data obtained from users ("you" or "your") who access or use the jjwan online betting and gaming platform available at https://jjwan.cam (the "Platform").

jjwan is committed to protecting the privacy and security of all personal data entrusted to us. We process personal data in accordance with applicable data protection principles, including purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and accountability.

By registering an account, making a deposit or otherwise using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with our data practices as described herein, you must not use the Platform.

2. Definitions

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, contact details, financial information, device identifiers and online identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this case, jjwan.
• "Data Processor" means a third party that processes personal data on behalf of jjwan under a data processing agreement.
• "User" means any individual who accesses or uses the Platform, whether as a registered account holder or as a visitor.
• "KYC" means Know Your Customer — the identity and age verification process conducted by jjwan as part of its compliance obligations.
• "Cookies" means small text files placed on your device by the Platform to facilitate functionality, analytics and, where consented to, personalisation.

3. Data Controller Identity

The data controller responsible for personal data collected through the Platform is jjwan, operating the website at https://jjwan.cam. For all data protection enquiries, requests and complaints, users should contact jjwan's support team using the details set out in Section 15 of this Policy.

4. Personal Data We Collect

jjwan collects personal data through multiple channels — directly from you during registration and account use, automatically through your use of the Platform, and from third-party verification and payment service providers. The categories of personal data we collect include the following:

4.1 Registration & Account Data

• Full legal name and date of birth.
• Email address and mobile telephone number.
• Residential address, including city (which may include cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar) and postal code.
• Username and encrypted password credentials.
• Account preferences and communication settings.

4.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents (e.g., Pakistani CNIC, passport).
• Proof of address documents (e.g., utility bills, bank statements).
• Selfie or biometric data where required by the verification provider to match identity documents.
• Source of funds documentation where applicable.

4.3 Financial & Transaction Data

• Deposit and withdrawal transaction history, all denominated in PKR.
• Payment method details (masked account numbers, wallet identifiers — full card numbers are not stored by jjwan and are handled exclusively by PCI-DSS compliant payment processors).
• Bonus and promotional account activity.

4.4 Betting & Gaming Activity

• Bet history, stakes placed, markets selected and outcomes.
• Casino game sessions, game types accessed and session durations.
• Responsible gambling limit settings and self-exclusion records.

4.5 Technical & Device Data

• IP address, device type, operating system and browser type.
• Geolocation data (country-level only, derived from IP address).
• Session logs, page visit timestamps and navigation patterns.
• Cookie and tracking technology data as described in Section 10.

4.6 Communications Data

• Records of communications with our support team, including live chat transcripts and email correspondence.
• Feedback, complaints and dispute correspondence.

5. How We Use Your Personal Data

jjwan processes your personal data for the following purposes:

• Account Management: Creating, operating and maintaining your jjwan account, including authentication and access control.
• Service Delivery: Processing deposits and withdrawals (in PKR), settling bets, awarding bonuses and providing access to all Platform features and games.
• Identity Verification (KYC): Verifying your age, identity and source of funds to comply with anti-money laundering (AML) and counter-terrorist financing (CTF) obligations.
• Fraud & Security: Detecting, investigating and preventing fraudulent activity, account misuse, multi-accounting, bonus abuse and other prohibited conduct described in our Terms and Conditions.
• Responsible Gambling: Monitoring account activity to support responsible gambling obligations, processing limit requests and self-exclusion elections.
• Customer Support: Responding to enquiries, resolving complaints and providing technical assistance through live chat, email and other support channels.
• Legal & Regulatory Compliance: Meeting obligations under applicable law, responding to lawful requests from competent authorities and maintaining records required by our operating licence.
• Service Improvement: Analysing aggregated, anonymised platform usage data to improve performance, user experience and product development.
• Marketing Communications: Where you have given your explicit consent, sending promotional communications about offers, bonuses and platform updates. You may withdraw consent at any time.

6. Legal Basis for Processing

jjwan processes personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract with you (i.e., operating your account and delivering the Platform's services).
• Legal Obligation: Processing is required to comply with applicable legal and regulatory obligations, including AML/KYC requirements and record-keeping obligations under the applicable licence.
• Legitimate Interests: Processing is necessary for jjwan's legitimate interests, including fraud prevention, platform security, responsible gambling monitoring and service improvement, where those interests are not overridden by your fundamental rights.
• Consent: Where you have expressly consented — specifically for marketing communications and non-essential cookies. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

jjwan does not sell, rent or trade your personal data to third parties for commercial purposes. We share personal data only in the following circumstances, and only to the extent strictly necessary:

7.1 Payment Processors

To process deposits and withdrawals, we share relevant financial and identity data with payment service providers. These providers may include payment gateway operators associated with methods familiar to Pakistani users such as bank transfer and digital wallet services. All payment processors are bound by contractual data processing obligations and applicable financial regulations. Payment provider names are referenced as contextual familiarity only — we do not claim that any specific provider endorses or supports jjwan.

7.2 KYC & Identity Verification Providers

We engage specialist identity verification service providers to assist with KYC compliance. These providers receive the documentation and data necessary to perform verification checks and return a verification outcome to jjwan. They do not retain your data beyond what is required for their contracted purpose.

7.3 Fraud Prevention & Risk Services

We share technical and account data with fraud prevention services to detect and prevent money laundering, multi-accounting and other prohibited activity. These services operate under strict contractual data processing restrictions.

7.4 Legal & Regulatory Authorities

We may disclose personal data to competent governmental, regulatory or law enforcement authorities where we are required to do so by applicable law, court order, or where disclosure is necessary to protect the rights, property or safety of jjwan or others.

7.5 Corporate Transactions

In the event of a merger, acquisition, restructuring or sale of assets, personal data may be transferred to the relevant acquiring or successor entity, subject to equivalent data protection obligations being maintained.

8. International Data Transfers

The Platform operates internationally and your personal data may be transferred to, stored or processed in countries outside Pakistan. These countries may have data protection laws that differ from those in your jurisdiction.

Where we transfer personal data internationally, we apply appropriate safeguards to protect the security and integrity of that data, including contractual data transfer mechanisms (such as standard contractual clauses) where required. We do not transfer personal data to jurisdictions that lack adequate protective measures without implementing such safeguards.

9. Data Retention

jjwan retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting or reporting requirements.

The following general retention guidelines apply:

• Account & KYC Data: Retained for a minimum of five (5) years following permanent account closure, in compliance with applicable AML and record-keeping obligations.
• Transaction Data: Retained for a minimum of five (5) years following the transaction date.
• Responsible Gambling Records: Self-exclusion and limit-setting records are retained for a minimum of five (5) years to prevent re-registration during an active exclusion period.
• Communications Data: Support correspondence is retained for a minimum of two (2) years from the date of the last interaction.
• Technical & Log Data: System and access logs are retained for up to twelve (12) months for security and fraud investigation purposes.

Where personal data is no longer required and no legal obligation mandates continued retention, it will be securely deleted or anonymised.

10. Cookies & Tracking Technologies

The Platform uses cookies and similar tracking technologies (including session tokens and pixel tags) to provide functionality, maintain session security, analyse usage patterns and deliver relevant content.

10.1 Types of Cookies

• Strictly Necessary Cookies: Required for the Platform to function correctly, including session management and login authentication. These cannot be disabled without breaking core functionality.
• Analytical Cookies: Used to collect aggregated, anonymised information about how Users interact with the Platform. We use this data to improve user experience and performance.
• Functional Cookies: Enable the Platform to remember your preferences, such as language settings and responsible gambling limit displays.
• Marketing Cookies: Used only where you have provided your consent to receive personalised promotional content. You may withdraw this consent at any time by adjusting your cookie settings.

10.2 Managing Cookies

You may control cookie settings through your browser's privacy settings. Please note that disabling strictly necessary cookies may impair the Platform's functionality. We do not use cookies to build persistent advertising profiles for sale to third parties.

11. Your Data Rights

Subject to applicable law and our legitimate compliance obligations, you have the following rights with respect to your personal data:

• Right of Access: You may request a copy of the personal data jjwan holds about you.
• Right of Rectification: You may request correction of inaccurate or incomplete personal data held about you.
• Right of Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restrict Processing: You may request that we limit the processing of your personal data in certain circumstances, for example where you contest its accuracy.
• Right to Object: You may object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to jjwan's assessment of whether those interests are overriding.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request receipt of your personal data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, submit a written request to our support team at [email protected]. We will respond within thirty (30) days. We may require identity verification before processing your request.

12. Minors & Age Protection

The Platform is strictly for adults. Access is limited to persons who are at least 18 years of age, or the higher minimum age required by the operator or the applicable license jurisdiction. We do not knowingly collect or process personal data relating to individuals under the applicable minimum age.

Where we identify or suspect that personal data has been provided by a minor, we will immediately suspend the relevant account, delete all associated personal data and decline any pending transactions. If you believe a minor has created an account on jjwan, please contact us immediately at [email protected].

13. Data Security

jjwan implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss or destruction. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data (including passwords and payment credentials) at rest using industry-standard encryption protocols.
• Access controls and role-based permissions restricting access to personal data to authorised personnel only.
• Two-factor authentication for internal administrative systems.
• Regular security vulnerability assessments and penetration testing.
• Incident response procedures to detect, report and manage personal data breaches.

While we apply rigorous security standards, no system can guarantee absolute security. You are responsible for maintaining the security of your own Account credentials. In the event of a security incident that materially affects your personal data, jjwan will notify you in accordance with its obligations under applicable law.

14. Changes to This Policy

jjwan reserves the right to update or modify this Privacy Policy at any time. Where changes are material, we will notify registered Users by email or by displaying a prominent notice on the Platform prior to the effective date of the change.

The revised Policy will be published on this page with an updated effective date. Your continued use of the Platform following publication of a revised Policy constitutes your acceptance of the changes. We therefore encourage you to review this page periodically.

If you have any objection to a material change to this Policy, you must cease using the Platform and may request Account closure before the revised Policy takes effect.

15. Contact Us

For all privacy-related requests, enquiries and complaints — including requests to exercise your data rights — please contact jjwan's support team. All correspondence must be submitted in English. We aim to acknowledge privacy requests within five (5) business days and to resolve them within thirty (30) days.

Support is available in English. Urdu language assistance may be available on request. When submitting a data rights request, please include your registered email address and a clear description of the right you wish to exercise to facilitate prompt handling.